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The July 2021 OECD Statement on a Two-Pillar Solution provided that the Pillar Two GloBE rules have the status of a ‘common approach’. This means that members of the Inclusive Framework (IF) are not required to adopt them (ie they are not compulsory), but, if they do, they need to implement and administer them in a way that is consistent with the outcomes provided for under Pillar Two.
In addition, members of the IF are required to accept the application of the GloBE rules applied by other members, including (crucially) agreement on the rule order and the application of any agreed safe harbors.
If jurisdictions do want to implement the GloBE rules, both the Income Inclusion Rule (IIR) and Under-taxed Payments Rule (UTPR) will need to be implemented through domestic legislation.
The Subject-To-Tax Rule (STTR), as a treaty-based rule, can only be implemented through bilateral negotiations and amendments to individual treaties or as part of a multilateral convention.
The OECD provides that members of the IF that apply nominal corporate income tax rates below the STTR minimum rate will implement the STTR into their bilateral treaties with developing country members of the IF when requested to do so.
The OECD published Model GloBE rules in December 2021 and Commentary in March 2022.
On December 20, 2022, the OECD issued the Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two), which includes details of two safe harbours and penalty relief for the Pillar Two GloBE rules.
| Country | GloBE Country Guide | Legislation | Guidance | Other Analysis |
|---|---|---|---|---|
| Australia | Australia: GloBE Country Guide | On December 23, 2024, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 to provide for the detailed application of the Pillar 2 GloBE rules in Australia. On July 4, 2024, draft legislation was submitted to Parliament. This includes the Taxation (Multinational-Global and Domestic Minimum Tax) Bill 2024, Taxation (Multinational-Global and Domestic Minimum Tax) Imposition Bill 2024 and the Treasury Laws Amendment (Multinational-Global and Domestic Minimum Tax) (Consequential) Bill 2024. These were passed by Parliament on November 26, 2024. They received Royal Assent on December 10, 2024: Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) Act 2024 Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Act 2024 On March 21, 2024, the Australian Treasury released draft legislation and draft rules as part of a consultation to implement the Pillar Two GloBE Rules. This includes an IIR, UTPR and a domestic minimum tax. Explanatory notes were also issued. | Final Explanatory Notes Explanatory notes 1 Explanatory Notes 2 | A Review of the Australian Global Minimum Tax Rules Australia Issues Rules for the Detailed Application of the Global Minimum Tax Australia Enacts Pillar 2 Laws Australian Senate Passes GMT Bills Australia Submits Pillar 2 Laws to Parliament A Review of Australia’s Draft Pillar Two Legislation |
| Austria | Austria: GloBE Country Guide | On July 19, 2024, the Tax Amendment Act 2024 was published in the Official Gazette, which includes various amendments to the Minimum Tax Act arising from the OECD Administrative Guidance, including currency provisions, extending the Transitional CbCR Safe Harbour to cases where an MNE is not required to prepare CbC Reports, and MTTCs. On December 30, 2023, the Austrian Federal Law Gazette No. 187/2023 published the Minimum Taxation Reform Act to implement the EU Minimum Tax Directive from January 1, 2024. On December 14, 2023, the Austrian National Council passed the Draft Pillar Two Law. On October 3, 2023, the Austrian Federal Ministry of Finance issued the ‘Federal law enacting the Federal Act to Ensure a Global Minimum Taxation for Groups of Companies’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. See our English Translation | Explanatory Notes | Austria Updates Minimum Tax Act for Aspects of OECD Administrative Guidance A Review of Austria’s Draft Pillar Two Law |
| Bahamas | The Bahamas: GloBE Country Guide | On October 16, 2024, the government tabled in Parliament the Domestic Minimum Top-Up Tax Bill 2024, which seeks to introduce an effective tax rate of 15 percent via a QDMTT for in-scope multinational enterprises operating in The Bahamas that have an annual consolidated revenue of or above 750 million euros. It was passed by the House of Assembly on November 6, 2024 and the Senate on November 18, 2024 and published in the Official Gazette on November 29, 2024. On August 12, 2024, the Government of the Bahamas issued a consultation paper including draft legislation (the ‘Domestic Minimum Top-Up Tax Bill, 2024) on a domestic minimum top-up tax (‘DMTT’), intended to be a Qualified Domestic Minimum Top-Up Tax. | A Review of The Bahamas Pillar 2 Domestic Minimum Tax The Bahamas Issues a Policy Paper on a New CIT System, Including a QDMTT |
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| Bahrain | Bahrain: GloBE Country Guide | On December 15, 2024, Bahrain issued Decision no. (172) of 2024 to provide for the Executive Regulations for the DMTT law. This provides the detailed rules for the operation of the DMTT. On September 1, 2024, Bahrain’s National Bureau for Revenue published Decree-Law No. (11) of 2024 for the introduction of a QDMTT. | Entities in Scope of DMTT Guide | Bahrain Issues Executive Regulations for the 2025 Domestic Top-Up Tax |
| Barbados | Barbados: GloBE Country Guide | On 7 May 2024, the Senate passed the Corporation Top-up Tax Bill, 2024 . This was published in the Official Gazette on May 24, 2024. | – | A Review of Barbados’s Conditional Domestic Minimum Tax Bermuda and Barbados Announce GloBE Implementation |
| Belgium | Belgium: GloBE Country Guide | On April 10, 2025, Belgium’s Ministry of Finance released the QDMTT Return. This is still considered in draft form until it has been published in the Official Gazette. On October 18, 2024, Belgium issued a draft QDMTT Return for consultation. The consultation lasts until November 8, 2024. On 16 July 2024, Belgium published the Royal Decree of 7 July 2024 in the Official Gazette, which establishes the rules for companies to make advance payments of the minimum tax under Pillar 2. On May 29, 2024, the Royal Decree of 15 May 2024 was published in the Official Gazette. This sets the GloBE Notification requirements. On May 12, 2024, the Belgian Official Gazette published a law which includes provisions to amend the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ to implement the OECD Administrative Guidance. On December 28, 2023, the Belgian Official Gazette published the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ to implement the EU Minimum Tax Directive from January 1, 2024. On December 14, 2023, the Belgian parliament adopted the draft law to implement the EU Minimum Tax Directive. On November 30, 2023, the Belgian House of Representatives adopted the draft law No. 55K3678 to implement the EU Minimum Tax Directive. The law will be enacted after it has been promulgated by the King and published in the official journal. The draft law was passed with no amendments. On November 13, 2023, draft law No. 55K3678 to implement the EU Minimum Tax Directive was sent to the Belgian Parliament. | Tax Authority FAQs on the Belgian Registration Process | Belgium Issues its QDMTT Return Belgium Issues a Draft 7 Page QDMTT Return for Consultation Belgium Extends Registration Deadline to September 16, 2024 if no 2024 GMT Advance Payments Belgian Royal Decree Sets July 13, 2024 as the Deadline for the First GloBE Notification Form Belgium Issues Draft Law to Implement the OECD Administrative Guidance A Review of Belgium’s Draft Pillar Two Law |
| Bermuda | – | On December 28, 2023, the Corporate Income Tax Act, 2023 (Act No. 35/2023) was published in the Official Gazette. On December 8, 2023, the Corporate Income Tax Act 2023 was tabled in the House of Assembly. | Bermuda Issues Draft Corporate Income Tax Law | |
| Bulgaria | Bulgaria: GloBE Country Guide | On March 27, 2025, Bulgaria’s 2025 State Budget Law was published in the Official Gazette. This includes a number of changes to the Corporate Income Tax Law to amend the Global Minimum Tax provisions from January 1, 2024. On September 18, 2024, the Bulgarian Ministry of Finance published for public consultation draft legislation to amend the Bulgarian minimum taxation rules, including the introduction of the Transitional UTPR Safe Harbour. This was submitted to Parliament on December 2, 2024. Updated draft legislation was issued by the Ministry of Finance on February 18, 2025. On December 22, 2023, the Law Amending the Corporate Income Tax Act (to implement the EU Minimum Tax Directive), was published in Issue 106 of the Official Gazette. On December 13, 2023, the Bulgarian Parliament approved the amendments to the Corporate Income Tax Act to implement the Pillar 2 GloBE rules. The law needs to be signed by the President to be enacted. On September 26, 2023, the Bulgarian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. See our English Translation | Bulgaria Gazettes its 2025 Budget Law which Includes Numerous Changes to the Global Minimum Tax Regime Bulgaria’s GMT Amendment Act Sent to Parliament Bulgaria Issues a Draft Law to Provide for OECD Administrative Guidance, Including the UTPR Safe Harbour A Review of Bulgaria’s Draft Pillar Two Law |
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| Brazil | Brazil: GloBE Country Guide | On December 30, 2024, Brazil’s President enacted Law No. 15,079, of December 27, 2024, that repeats (with minor amendments) Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025. On December 31, 2024, Normative Instruction No. 2245, of December 30, 2024 was issued which implements the detailed regulations for the provisions of the domestic minimum tax as provided in Normative Instruction No. 2,228, of October 3, 2024, with a number of amendments. On October 3, 2024, Brazil issued Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025. It is designed to meet the requirements of the OECD Model Rules and Administrative Guidance and qualify as a Qualified Domestic Minimum Top-Up Tax for GloBE purposes. If the Provisional Measure is not ratified by Congress, it will become ineffective. On December 17, 2024, the Chamber of Deputies approved Bill 3817/24 that repeats the provisional measure and implements the DMT. On December 18, 2024, it was approved by the Senate. Normative Instruction No. 2,228, of October 3, 2024 was also issued to regulate the application of the QDMTT. | – | Brazil Enacts Domestic Minimum Tax Law and Issues Amended Regulations Brazils Chamber of Deputies Ratifies Bill to Approve Provisional Measure No. 1,262/2024 to introduce a Domestic Minimum Tax Brazil Issues Legislation to Implement a QDMTT From January 1, 2025 |
| Canada | Canada: GloBE Country Guide | On August 12, 2024, draft legislative proposals (the ‘2024 Draft Law’) were issued to provide for the Under-Taxed Profits Rule (UTPR) for fiscal years beginning on or after December 31, 2024 (as well as limited other amendments for the Fourth Set of OECD Administrative Guidance). On June 20, 2024, the Global Minimum Tax Act (included in the Budget Implementation Act 2024, No. 1) received royal assent. This includes provisions to implement an IIR and a QDMTT from December 31, 2023. On August 4, 2023, Canada issued the draft Global Minimum Tax Act for consultation. | Explanatory Notes Table of Concordance | Canada Issues Explanatory Notes on the Global Minimum Tax A Review of Canada’s Draft GloBE Law |
| Croatia | Croatia: GloBE Country Guide | On December 22, 2023, Law No 155/23, to implement the EU Minimum Tax Directive, was published in the Official Gazette. On November 30, 2023, the Croatian government sent a draft bill to implement the Pillar Two GloBE rules to Parliament. | Explanation | |
| Curacao | Curacao: GloBE Country Guide | On December 20, 2024, Curacao’s Global Minimum Tax Ordinance was approved by Parliament and it was published on December 27, 2024. This includes an IIR and a QDMTT from January 1, 2025: On November 1 and 4, 2024, the Council of Ministers sent the draft National Ordinance on Minimum Tax to the SER (case number 2024/ 012811) and RVA (case number RA/37-24-LV) for review. | Explanatory Notes | Curacao Issues Draft Global Minimum Tax Ordinance |
| Cyprus | Cyprus: GloBE Country Guide | On 12 December 2024, the Cyprus House of Representatives voted to approve local legislation to implement Pillar 2. The Law was published in the Official Government Gazette on December 18, 2024. On October 18, 2024, a bill was tabled in Parliament to introduce the mandatory Income Inclusion Rule (IIR) for fiscal years beginning from December 31, 2023, and the Undertaxed Profits Rule (UTPR) for fiscal years starting from December 31, 2024. A DMTT will be implemented for fiscal years beginning December 31, 2024. The IIR, which should have been approved by the end of 2023, will apply retroactively from December 31, 2023. On July 24, 2024, the Ministry of Finance announced the domestic application of all OECD Safe Harbours as provided in the Safe Harbours & Penalty Relief Guidance and other Administrative Guidance. On October 3, 2023, the Cyprus Ministry of Finance issued the ‘Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union Law of 2023’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. See our English Translation | A Detailed Review of the Cyprus Global Minimum Tax Law Cyprus Parliament Approves Pillar 2 Law Cypriot GMT Law Tabled in Parliament Includes Detailed QDMTT Provisions Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament A Review of Cyprus’s Draft Pillar Two Law |
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| Czech Republic | Czech Republic: GloBE Country Guide | On April 26, 2024, the Czech government issued a draft law to amend the minimum tax act to implement aspects of the OECD Administrative Guidance. This was submitted to Parliament on August 28, 2024. On December 29, 2023, Law 416/2023, to implement the EU Minimum Tax Directive, was published in the Czech Official Gazette. On August 16, 2023, the Czech Cabinet approved the draft top-up tax act. On December 1, 2023, the Czech Senate approved the draft top-up tax act. See our English Translation | Explanatory Notes for the April 2024 Draft Law (December 2023 Administrative Guidance) Regulatory Report | Czech Republic Amends Draft Law Amending its GloBE Law A Review of the Czech Draft Top-Up Tax Act |
| Denmark | Denmark: GloBE Country Guide | On February 3, 2025, the Danish Ministry of Finance issued draft legislation (Bill 2024-4606) for consultation. This is to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance. On February 18, 2025, the Executive Order on registration requirements was published in the Official Gazette. On June 11, 2024, Law No. 684 was published in the Danish Official Gazette. This implements additional aspects of the OECD Administrative Guidance. The Danish Minimum Taxation Act was enacted as Law No. 1535 of December 12, 2023. On June 23, 2023, the Danish Ministry of Taxation issued the draft Minimum Tax Act (the ‘Bill’) to give effect to the GloBE rules. | Report of Committee on Taxation | Denmark Issues a Draft Law for June 2024 and January 2025 OECD Administrative Guidance Denmark GloBE Country Guide: Updated for June 2024 Amending Law A Review of the Danish Draft Minimum Tax Act |
| Estonia | Estonia: GloBE Country Guide | On May 2, 2024, the Estonian Official Gazette enacted the ‘Act supplementing the Tax Information Exchange Act, the Tax Administration Act and the Income Tax Act’ to implement the EU Global Minimum Tax Directive. On February 8, 2024, the ‘Act supplementing the Tax Information Exchange Act, the Tax Administration Act and the Income Tax Act’ to implement the EU Global Minimum Tax Directive was approved by the Estonian Government and sent to Parliament. It was approved by Parliament on April 10, 2024. However, as Estonia intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). | Estonia Issues Draft Pillar 2 Law Including Art. 50 Postponement | |
| EU | – | On October 28, 2024, the EU Commission adopted a proposal to amend the Directive on administrative cooperation in the field of taxation (Directive 2011/16/EU – DAC) (DAC 9). The goal is to make it easier for companies to fulfil their filing obligations under the Pillar 2 Directive. This was approved by the EU Council on April 14, 2025. On December 12, 2023 the EU Commission published the Commission Notice to Elect to delay application of the IIR and UTPR under Article 50 of the Pillar Two Directive. The European Commission released a proposed directive based on the model GloBE rules on December 22, 2021. On December 15, 2022, the Council of the European Union formally adopted the EU Pillar Two directive. Member states will have to transpose the directive into national law by the end of 2023. On December 22, 2022 the EU Global Minimum Tax Directive was published in the EU official journal as Council Directive (EU) 2022/2523 of 14 December 2022. Date of entry into force: 23 December 2022. | FAQ document | EU Issues DAC 9 Proposal for Centralised GIR Filing Within the EU The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) EU Issues Commission Notice For Jurisdictions Delaying the IIR/UTPR Full Steam Ahead For EU Pillar Two Implementation Review of the Draft EU Pillar Two Directive Poland Withdraws its Veto and the EU Pillar Two Directive is Adopted |
| Finland | Finland: GloBE Country Guide | On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, including provisions from the OECD June 2024 Administrative Guidance relating to the DTL recapture. On August 12, 2024, the Finnish government issued draft legislation to amend its Global Minimum Tax Act to reflect aspects of the 2023 OECD Administrative Guidance. The draft law is subject to a consultation until September 6, 2024. On September 19, 2024, the draft law to amend the Minimum Tax Act was sent to Parliament. The amended legislation was published in the Official Gazette on December 19, 2024 On December 28, 2023, the Finnish President approved the ‘Law on the Minimum Taxation for Corporations’, which implements the EU Minimum Tax Directive. On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. See our English Translation | Explanatory Guidance of March 10, 2025: General Explanatory Guidance of March 12, 2025: Adjusted Covered Taxes Explanation | Finland Issues Guidance for the Application of the Global Minimum Tax Finland’s Amendment Law and its Impact on the Global Minimum Tax Provisions Finland Issues Draft Pillar 2 Amendment Law to Reflect OECD Administrative Guidance Key Aspects of Finland’s Draft GloBE Law |
| France | France: GloBE Country Guide | On February 15, 2025, the French Finance Act 2025 was published in the Official Gazette. Article 53 includes amendments to the French Global Minimum Tax Regime for the OECD Administrative Guidance. On December 5, 2024, Decree No. 2024-1126 was published in the French Official Gazette. This provides additional details on the reporting requirements for Pillar 2 purposes. The Pillar 2 Notification Form (N° 2065-INT-SD 2025) was subsequently issued. On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. This includes amendments to its GMT law to reflect the OECD Administrative Guidance, including the December 2023 OECD amendments to the Safe Harbours. On December 30, 2023, the French Official Gazette published the 2024 Finance Act. This includes provisions to enact the EU Minimum Tax Directive. On 21 December 2023, the French Parliament approved the Finance Bill for 2024. Article 4 of the French 2024 Finance Bill (published on September 27, 2023) includes provisions to implement the EU Global Minimum Tax Directive. See our English Translation | French 2025 Finance Act Includes Pillar 2 Changes for OECD Administrative Guidance A Detailed Review of France’s Global Minimum Tax Law France Issues a Decree for Pillar 2 Reporting Requirements France GloBE Country Guide Updated for the 2025 Finance Bill A Review of France’s Draft Pillar Two Law |
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| Germany | Germany: GloBE Country Guide | On April 3, 2025, the German Tax Authority issued a letter on the treatment of fiscally transparent partnerships (such as domestic or foreign partnerships that are not subject to corporate income tax) for CbCR purposes and for the purposes of the Pillar 2 Transitional CbCR Safe Harbour. On December 6, 2024, the Federal Ministry of Finance issued a Second Discussion Draft on amendments to the Minimum Tax Act. The updated Second Discussion Draft includes amendments for the June 2024 OECD Administrative Guidance. On November 22, 2024, the Annual Tax Act was passed by the Upper House of Parliament. This includes two technical changes to the German GMT law. On October 17, 2024, Germany released the template for its Group Leader Notification Form (updated on March 11, 2025). On August 20, 2024, the German Ministry of Finance issued a Discussion Draft of a Draft Law to implement most aspects of the Third Set of OECD Administrative Guidance. On June 5, 2024, the German Federal Ministry of Finance published the government draft for an Annual Tax Act 2024. This includes an amendment to the minimum tax act to implement the provision relating to the calculation of the SBIE for mobile employees in the Second Set of OECD Administrative Guidance. On May 17, 2024, the Germany Finance Ministry issued a draft Global Minimum Tax Return to specialist publishers, software providers and associations for feedback. On December 27, 2023, Germany’s law to implement the Pillar 2 GloBE Rules/EU Minimum Tax Directive was published in the Federal Law Gazette 2023. The Bundesrat (Germany’s Upper House of parliament) passed the ‘Act on the implementation of Council Directive (EU) 2022/2523 to ensure a global minimum level of taxation and further accompanying measures’ . It requires Presidential approval for enactment. On November 10, 2023, the Bundestag (lower house) approved the German draft law to implement the EU Minimum Tax Directive. On August 16, 2023, the Federal Cabinet adopted the government draft for the implementation of the Pillar Two GloBE Rules. On July 10, 2023, the German Ministry of Finance issued an updated draft law for the implementation of the EU Global Minimum Tax Directive. On March 20, 2023, the German Federal Ministry of Finance published a consultation, including a draft law (the Minimum Taxation Directive Implementation Act), to implement the EU Global Minimum Tax Directive. See our English Translation | Second Discussion Draft of December 6, 2024 | Germany Issues Guidance on the Treatment of Tax Transparent Partnerships for the CbCR Safe Harbour Germany Issues a Second Discussion Draft to Amend its GMT Law for June 2024 OECD Guidance German Annual Tax Act Includes GMT Amendments Germany Releases its Group Parent Notification Form for German Minimum Tax Groups Germany Includes an Amendment to its GMT Law in the Draft Annual Tax Act Germany Issues Draft GMT Return For Feedback Germany Approves and Updates its GloBE Law Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law Germany Publishes Draft Global Minimum Tax Legislation |
| Gibraltar | Gibraltar: GloBE Country Guide | On February 20, 2025, Gibraltar issued the Income Tax (Allowances, Deductions, and Exemptions) (Amendment) Rules 2025 which allows in-scope MNEs to elect to just be taxed under the Global Minimum Tax Act, and not the Income Tax Act. On December 10, 2024, Gibraltar published draft legislation to implement a DMTT for fiscal years starting from December 31, 2023 as well as an IIR for fiscal years starting from December 31, 2024. The Global Minimum Tax Act 2024 was enacted on December 23, 2024. | – | Gibraltar Issues Simplification Measure for MNEs to Simplify Global Minimum Tax Compliance Gibraltar Issues Draft GloBE Law for a DMTT and IIR |
| Greece | Greece: GloBE Country Guide | On April 5, 2024, Law 5100/2024 was published in the Official Gazette. This implements the EU Minimum Tax Directive in Greece from December 31, 2023 (with the UTPR applying from December 31, 2024). On February 22, 2024, the Ministry of National Economy and Finance entitled issued a draft law to implement the EU Global Minimum Tax Directive. The draft law is subject to consultation until March 6, 2024. The draft law includes an IIR and QDMTT from December 31, 2023 and a UTPR from December 31, 2024. | Explanation | A Review of Greece’s Draft Pillar Two Law |
| Guernsey | Guernsey: GloBE Country Guide | On November 26, 2024, Guernsey issued the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar Two GloBE Model Rules) Regulations, 2024 to transpose the OECD Model Rules into domestic law | Implementation of the GloBE rules in Guernsey | Guernsey Enacts its Global Minimum Tax Law |
| Hong Kong | Hong Kong: GloBE Country Guide | In April 2025, the Hong Kong Government proposed a number of Committee Stage Amendments to the Bill. On December 27, 2024, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Official Gazette. This is to introduce an IIR and QDMTT from January 1, 2025, and the UTPR from a future date to be specified. The Bill will be introduced into the Legislative Council for first reading on January 8, 2025. On October 30, 2024, the Hong Kong government released the outcome statement following the previous consultation into the introduction of the GloBE rules. | – | Hong Kong Issues Draft Law for IIR and Domestic Top-Up Tax From January 1, 2025 Hong Kong Issues Outcome of the Consultation on the Introduction of the GloBE Rules |
| Hungary | Hungary: GloBE Country Guide | On November 15, 2024, the Hungarian Tax Authority issued draft forms for the registration notification under Article 44(1) of the Minimum Tax Act, and the appointment of a domestic filing entity under Article 3(47).In December 2024, the Hungarian Tax Authority issued Updated Instructions for the submission of the registration forms. They can now be submitted via the ONYA (Online Nyomtatványkitöltő Alkalmazás) web portal on the e-services portal of the Hungarian Tax Authority Website. On October 29, 2024, Hungary issued its Autumn 2024 Tax Package proposal. This included minor changes to the Pillar Two law. Most notably it expanded on the registration requirements. The Hungarian Autumn Tax Package (Bill T/9724 on Amendments to Certain Tax Laws) has been approved by Parliament and was sent to the President for signature on November 27, 2024. On November 28, 2024, this was published in the Official Gazette. On November 30, 2023, Act LXXXIV of 2023 on ‘Additional taxes ensuring a global minimum tax level and amending certain tax laws in connection with this’ was published in issue 171/2023 of the Hungarian Gazette. See our English Translation | Updated Instructions for the Registration Form Explanation 1 Explanation 2 | Hungary GloBE Registration Form Available for Submission Hungary Issues GloBE Registration Form and Domestic Filing Entity Form GMT Amendments in the Hungarian Autumn Tax Package Passed to President for Signature Hungary Includes GloBE Amendments in its 2024 Autumn Tax Proposal Hungary Approves and Updates its GloBE Law A Review of Hungary’s Draft Pillar Two Law |
| Isle of Man | Isle of Man: GloBE Country Guide | On November 21, 2024, the Isle of Man Parliament passed the Global Minimum Tax (Pillar Two) Order 2024 On October 24, 2024, the Isle of Man income tax division published an update on the implementation of the GloBE rules in a letter sent to all Isle of Man entities likely to be within the scope of the new rules. The draft legislation is available and will be considered by the Parliament in November 2024. The Isle of Man is applying an IIR and a QDMTT. The legislation transposes the GloBE model rules and commentary/AG into domestic law with some modifications. | On April 24, 2025, the Online Service was launched. This is currently limited to registration and adding group details. Filing returns is not yet supported. Guidance note 64 provides details of the service. | Isle of Man Issues the Cessation Form for Pillar 2 Domestic Top-Up Tax Isle of Man Parliament Passes the Global Minimum Tax (Pillar Two) Order 2024 Isle of Man Issues Draft Legislation for the IIR and QDMTT from 2025 |
| Indonesia | Indonesia: GloBE Country Guide | On December 31, 2024 the Ministry of Finance issued Minister of Finance Regulation Number 136 of 2024 regarding the imposition of a global minimum tax which will take effect from January 1, 2025. On December 20, 2022, Indonesia issued Government Regulation No. 55/2022 on the Adjustment of Regulations in the Field of Income Tax. This included reference to the implementation of a global minimum tax in Indonesia as well as a desire to implement Pillar One. | Indonesia Publishes Regulation for IIR, UTPR and Domestic Minimum Tax Indonesian Regulation Signals Global Minimum Tax Implementation |
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| Ireland | Ireland: GloBE Country Guide | On October 25, 2024, the Ministry of Finance issued S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 to provide for the application of the June 2024 OECD Administrative Guidance. On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions. This was approved by the lower house of Parliament on November 5, 2024 and signed into law by the President on November 12, 2024. On August 8, 2024, the Irish Revenue issued eBrief No. 213/24 concerning new guidance on the administration of the Pillar 2 global minimum tax, as well as updated guidance on the operation of the Pillar 2 rules. On December 22, 2023, the Minister of Finance issued S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 to provide that the December 2023 OECD Adminstrative Guidance applies in Ireland. On December 18, 2023, the Irish President enacted the Finance (No. 2) Act 2023 (Act 39 of 2023) to implement the EU Minimum Tax Directive. On October 19, 2023, the Irish Ministry of Finance released the Finance (No. 2) Bill 2023. This inserts a new Part 4A into the Taxes Consolidation Act, 1997 to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. On July 27, 2023, Ireland issued its Second Feedback Statement on Pillar Two. On March 31, 2023, the Irish government issued a Feedback Statement on the Pillar Two Global Minimum Tax. It includes draft legislation and outlines possible draft legislative approaches to key elements of the GloBE Rules. | Revenue eBrief No. 045/25 of February 17, 2025. Revenue eBrief No.322/24 of December 17, 2024 eBrief No. 213/24 Tax & Duty Manual: Pillar 2 Revenue eBrief No. 136/24 Explanation | Ireland’s 2024 Finance Act Includes Numerous GMT Adjustments for the OECD Administrative Guidance Ireland GloBE Country Guide Updated for the 2024 Finance Bill A Review of Ireland’s Draft Pillar Two Law A Review of Ireland’s Draft Pillar Two Law Ireland Issues Second Feedback Statement on Pillar Two Ireland Issues Draft Global Minimum Tax Law For Feedback |
| Italy | Italy: GloBE Country Guide | On March 6, 2025 a Decree of the Italian Ministry of Finance on Notification Requirements for Global Minimum Tax purposes was published in the Official Gazette. This provides more details on the double filing relief notification under Article 51(4) of Legislative Decree December 27, 2023, no. 209. On December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements the OECD Administrative Guidance on the treatment of deferred taxation generated in the period prior to the implementation of the GloBE rules. On December 30, 2024, Ministerial Decree of December 20, 2024 was published in the Official Gazette. This addresses miscellaneous aspects of the GloBE Rules/Administrative Guidance (including the Forex Hedge election, debt release election and sovereign wealth funds). On October 15, 2024, Italy issued Decree 11, of October 2024 on the calculation of the Substance-based Income Exclusion under Pillar 2. This includes all of the OECD Administrative Guidance on the SBIE. On July 3, 2024, the Italian Ministry of Economy & Finance issued a Decree which contains the procedures for the implementation of the Qualified Domestic Minimum Top-up Tax (QDMTT). On May 21, 2024, Italy’s Ministry of Economy & Finance issued a Decree for the detailed application of the Transitional CbCR and UTPR Safe Harbours. On December 28, 2023, the Italian Official Gazette published Legislative Decree No. 209 of December 27, 2023 which implements the EU Minimum Tax Directive. On September 11, 2023, the Italian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive (the ‘EU Directive’). See our English Translation | Explanatory Report to the December 30, 2024 Ministerial Decree Explanatory Notes to the December 20, 2024 Ministerial Decree Explanatory Notes on the SBIE Decree Technical explanation of the Transitional Safe Harbours Decree | Italy Issues Decree for Double Filing Relief Notification Under the Pillar 2 Rules Italy Issues a Ministerial Decree to Implement Various Aspects of the OECD Administrative Guidance Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance Detailed Analysis of the Italian QDMTT Implementing Decree Italy Issues a Decree for the Transitional CbCR & UTPR Safe Harbours A Review of Italy’s Draft Pillar Two Law |
| Japan | Japan: GloBE Country Guide | On March 31, 2025, the amendment laws to implement the UTPR and QDMTT in Japan from April 1, 2026 were published in the Official Gazette. On February 4, 2025, Japan submitted the draft tax reform bill for 2025 to Parliament. This includes a QDMTT and UTPR from April 1, 2026. On January 28, 2025. the National Tax Agency revised the “Q&A on the Global Minimum Tax” for determining whether laws and regulations relating to the QDMTT Safe Harbour meet the requirements of the QDMTT accounting standard and consistency standard. On December 20, 2024, Japan announced in its 2025 Tax Reform that the UTPR and a QDMTT will be applied from April 1, 2026. On April 26, 2024, the Japanese National Tax Agency issued detailed explanatory notes on the application of Japan’s Pillar Two law/ordinance. On April 12, 2024, the “Ministerial Ordinance to Partially Amend the Enforcement Regulations of the Corporation Tax Law” was published in the Official Gazette. This includes tax return forms (in Japanese) for reporting top-up tax under Japan’s Income Inclusion Rule. The top up forms are included in Appendix 20 of the Enforcement Regulations to the Corporation Tax Law, and can be viewed at: Top-up tax forms. On December 25, 2023, Japan’s National Tax Agency issued Frequently Asked Questions on the Japanese Income Inclusion Rule to apply from April 1, 2024. On October 20, 2023, the Japanese Ministry of Finance released its technical explanation of the Japanese Global Minimum Tax Laws and Regulations. On March 28, 2023, Japan enacted a domestic law to give effect to the Pillar Two GloBE rules from April 1, 2024. On June 30, 2023, Japan’s Ministry of Finance issued Ministry of Finance Ordinance No. 47 of 2023 Amending the Enforcement Regulations of the Corporation Tax Act. On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law was published in the Official Gazette. On September 29, 2023, the National Tax Agency published the “Partial Revision of the Basic Circular on Corporate Tax” which provides some administrative guidance on various aspects of Japan’s GloBE law. On February 3 and 6, 2023, the Ministry of Finance published the “Bill for the Partial Revision of the Income Tax Act”. This includes the implementation of the Pillar Two GloBE rules from April 2024. See our English Translation | Detailed Explanatory Notes Technical Explanation | Japan Enacts Law for QDMTT and UTPR from April 1, 2026 Japan Issues Circular for Additional GloBE Guidance What Japan’s Cabinet Order on Pillar 2 Includes & Doesn’t Include Overview of Japan’s Latest Ministerial Ordinance on Pillar 2 Overview of Japan’s Cabinet Order on the Global Minimum Tax Japan’s Global Minimum Tax Law Is Enacted GloBE Country Guide: Japan |
| Jersey | Jersey: GloBE Country Guide | On October 22, 2024, Jersey enacted the Multinational Corporate Income Tax (Jersey) Law 202 and the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202 to provide for the IIR and MCIT from January 1, 2025. On August 14, 2024, the Jersey Assembly accepted for consideration a draft Pillar 2 law ‘Draft Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202’ to implement an IIR as well as a ‘Draft Multinational Corporate Income Tax (Jersey) Law 202’ to implement a new multinational corporate income tax. | Pillar 2 Review | Jersey Enacts Law for the IIR and the MCIT |
| Kenya | – | On 4 November 2024, the Tax Laws (Amendment) Bill 2024 was introduced to the lower house of Parliament. The Bill includes a proposal for a minimum top-up tax of 15%. This was published in the Official Gazette on December 13, 2024. The law is very high level and while based on the Model GloBE rules, based on the current law this would not be a QDMTT (eg no CFC pushdown restriction, no safe harbours and no provisions for additional tax). On May 13, 2024 the Finance Bill, 2024 was sent to the Kenyan parliament. It includes provisions to introduce a 15% domestic minimum top-up tax from January 1, 2025. | – | Kenya Enacts a Domestic Minimum Tax in its Tax Laws (Amendment) Act, 2024 Kenya Includes a Domestic Minimum Tax in its 2024 Finance Bill |
| Kuwait | Kuwait: GloBE Country Guide | On December 30, 2024, Kuwait published Decree-Law 157 of 2024 for the introduction of a QDMTT from January 1, 2025. On December 9, 2024, the Kuwaiti Ministry of Finance issued a draft law that includes a 15% DMTT (from January 1, 2025) as part of its overhaul of the Business Profits Tax Regime. The detailed rules for calculation of the top-up tax are to be provided by Executive Regulations. See our English Translation | – | Kuwait Enacts its Domestic Minimum Top-Up Tax Kuwait Issues a Draft Law to Introduce a Domestic To-Up Tax from 2025 |
| Latvia | Latvia: GloBE Country Guide | On June 20, 2024, the Latvian global minimum tax law was published in the Official Gazette. On June 6, 2024 the Latvian Parliament adopted in its final reading the “Law on ensuring the global minimum tax level of large groups of companies”, which implements the EU Global Minimum Tax Directive. However, as Latvia intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). | Lithuania and Latvia Updates to the GloBE Country Guides Latvian Parliament Adopts Law to Implement EU Minimum Tax Directive Latvia Issues Draft Pillar Two Law & Confirms Postponement |
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| Liechtenstein | Liechtenstein: GloBE Country Guide | On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act. The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. On December 13, 2024, an Ordinance was published in the Official Gazette to amend the GloBE Regulation. On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette. On December 22, 2023, the Minimum Tax Act (to implement the GloBE Rules), was published in the Official Gazette of Liechtenstein, No. 2023/484. On March 29, 2023, Liechtenstein published draft legislation for the implementation of the Pillar Two Globe Rules. See our English Translation | Liechtenstein Government Approves a Draft Law for the Exchange of GIR Information Under the MCAA Liechtenstein Issues Pillar 2 Registration Rules Liechtenstein Gazettes Pillar Two Law A Review of the Liechtenstein GloBE Regulation Liechtenstein Publishes Draft Global Minimum Tax Law |
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| Lithuania | Lithuania: GloBE Country Guide | On September 19, 2024, the Lithuanian government launched a public consultation on a draft bill to fully implement the OECD’s Pillar Two Model Rules as set out under the EU Minimum Tax Directive. This follows the previous partial implementation of the GloBE Rules to defer implementation under Article 50 of the EU Minimum Tax Directive. On June 21, 2024 the Order on the procedures for the submission of information notifications in relation to the implementation of the Pillar 2 was published in the Official Gazette. On June 19, 2024, the Lithuanian global minimum tax law was published in the Official Gazette. This implements the Article 50 deferral of the EU Minimum Tax Directive. On June 6, 2024, the Lithuanian Parliament approved Law No. XIV-2680/2024 to implement the Art. 50 deferral in the EU Minimum Tax Directive. On March 14, 2024, the Lithuanian Parliament updated the draft GloBE Law. On October 27, 2023, Lithuania’s Ministry of Finance issued a draft law to implement the EU Global Minimum Tax Directive. However, as Lithuania intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). See our English Translation | Lithuania GloBE Country Guide Updated for Latest Draft Law Lithuania GloBE Guide – Updated for the Order on Information Notices Lithuania Issues Draft Pillar Two Law & Confirms Postponement |
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| Luxembourg | Luxembourg: GloBE Country Guide | On June 12, 2024, the Luxembourg Government published draft law amending the law of 22 December 2023 on the minimum effective taxation for multinational enterprise groups and large domestic groups. The draft law provides for a number of amendments in the December 2023 OECD Administrative Guidance. On October 31, 2024 additional amendments were made to the draft legislation to incorporate elements from the OECD June 2024 Administrative Guidance. The draft law was approved by Parliament on December 19, 2024 and published in the Official Gazette on December 23, 2024. On March 25, 2024, the Luxembourg Government issued a FAQ on its Pillar 2 law. On December 22, 2023, the Luxembourg Official Gazette published Law A864 to transpose the EU Minimum Tax Directive. Grand-Ducal Regulation of 22 December 2023 on the procedures for registration and deregistration, notification and filing of the information return for the supplementary tax with the Direct Tax Administration On 20 December 2023, the Luxembourg Parliament voted to approve the draft law n°8292 transposing the EU Minimum Tax Directive. On November 13, 2023, the Luxembourg Government issued amendments to update its draft law implementing the EU Minimum Tax Directive. On 4 August 2023, the Luxembourg government issued Draft Law No. 8292 to implement the EU Minimum Tax Directive. See our English Translations | FAQs | Luxembourg Parliament Approves Global Minimum Tax Amendment Law for OECD Administrative Guidance Luxembourg GloBE Guide Updated for October 2024 Amendments to Draft Law Luxembourg Government Approves Draft Law to Include Additional OECD Administrative Guidance Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance Key Aspects of Luxembourg’s Draft GloBE Law |
| Malaysia | Malaysia: GloBE Country Guide | On December 29, 2023, the Finance Act (No. 2) 2023 was published in the Official Gazette. This implements the Pillar Two GloBE rules in Malaysia from 2025. On December 13, 2023, the Malaysian Parliament approved the Finance Bill (No.2) 2023. | On December 2, 2024, the Malaysian Inland Revenue Board issued guidance on the interpretation and administration of the Pillar Two global minimum. FAQs | Malaysia Issues Guidelines for the Implementation of the Global Minimum Tax A Review of Malaysia’s Draft Pillar Two Law |
| Malta | Malta: GloBE Country Guide | On April 17, 2025, Act No. IX of 2025 was published in the Official Gazette. This includes a new Section 22B in the Income Tax Act to provide that rules will be issued to provide for an elective tax (likely to give Pillar Two in-scope companies the option to subject their profits to the elective tax in Malta to ensure that no top-up tax is due elsewhere). On February 28, 2024, the Maltese Tax Authorities issued a guidance note on the implementation of the EU Minimum tax Directive in Malta. On February 20, 2024, the Government issued Legal Notice 32 of 2024 which includes Regulations to implement Article 50 of the EU Minimum Tax Directive. However, as Malta intends to delay the application of the GloBE rules under Article 50 of the EU Directive, the law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). | Guidance Notes | Malta Enacts EU Minimum Tax Directive With Art. 50 Postponement |
| Mauritius | – | The Finance (Miscellaneous Provisions) Act 2022 which implements provisions of the 2022 Budget in Mauritius includes mention of a qualified domestic minimum tax for Pillar Two purposes. | Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax | |
| New Zealand | New Zealand: GloBE Country Guide | The Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Act, 2024 has been enacted, receiving Royal assent, March 28, 2024. On May 18, 2023, New Zealand published a draft law (the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill) to implement the Pillar Two Global Minimum Tax. On March 11, 2024, the Finance and Expenditure Committee of the New Zealand Parliament made a number of amendments to the draft law. | Commentary | The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) New Zealand Updates Draft Global Minimum Tax Law & Delays Domestic IIR to 2026 New Zealand Issues Draft Global Minimum Tax Law Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand |
| North Macedonia | North Macedonia: GloBE Country Guide | On January 3 2025 the Law on Global Minimum Corporate Income Tax was published in the Official Gazette. This applies the IIR and a DMTT from January 1, 2024 and the UTPR from January 1, 2025. | – | North Macedonia Enacts Global Minimum Tax Law From January 1, 2024 |
| Norway | Norway: GloBE Country Guide | On April 3, 2024, Regulations for the implementation of the GloBE law were issued. On June 19, 2024, the Norwegian Ministry of Finance initiated a consultation on the introduction of the UTPR. On October 7, the Norwegian government issued the proposal to introduce the UTPR. On June 25, 2024, the Norwegian GloBE law was amended. On January 12, 2024, the Norwegian Council of State ratified the Norwegian Parliaments enactment of the Supplementary Tax Act in Legislative Decision 37 (2023-2024) Act No. 1. (see Law-2024-01-12-1 ) On January 12, 2024, Amendments were made to the Tax Administration Act to reflect GloBE filing. On November 24, 2023, the draft law to implement the GloBE rules in Norwegian law from 2024 was submitted to Parliament. On June 6, 2023, the Norwegian Ministry of Finance launched a consultation (including draft legislation) on the implementation of the Pillar Two GloBE Rules in Norway. See our English Translation | Explanation | Norway GloBE Guide Updated for Amended Regulations Norway Sends its Updated GloBE Law to Parliament Norway Issues Consultation and Draft Law For Pillar 2 Rules |
| Oman | – | On December 31, 2024, Oman issued Royal Decree No. 70/2024 that promulgates the Global Minimum Tax Law on entities affiliated to multinational groups. It is to be published in the Official Gazette on Sunday at which point the attachments to the Decree (which contain the provisions of the GMT Law) will be available. It comes into force on January 1, 2025. | – | Oman Issues a Law to Introduce an IIR and Domestic Top-Up Tax from 2025 |
| Poland | Poland: GloBE Country Guide | On April 7, 2025, the Polish Ministry of Finance released details for a draft bill to amend the Minimum Tax Act. The amendments are to implement the June 2024 and January 2025 OECD Administrative Guidance. On February 12, 2025, the Polish Minster of Finance published in the Official Gazette a list of jurisdictions that have qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour. On November 19, 2024, the Global Minimum Tax Law was published in the Official Gazette. On November 15, 2024, Poland’s President approved the Global Minimum Tax Law. On November 7, 2024 the draft law implementing the EU Minimum Tax Directive in Poland was passed by the upper house of Parliament (with no amendments) and has been passed to the President for enactment. On April 25, 2024, the Polish Ministry of Finance issued a draft law to implement the EU Minimum Tax Directive from January 1, 2025 (with an option to apply the regulations retrospectively from 2024). On September 25, 2024, the draft bill was sent to the Polish Parliament. | Explanatory Notes | Poland Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2 Poland Enacts its Global Minimum Tax Law Poland to Delay Pillar Two Implementation to 2025 |
| Portugal | Portugal: GloBE Country Guide | On November 8, 2024, the law to transpose the EU Minimum Tax Directive was published in the Official Gazette. On October 30, 2024, the Portuguese President promulgated the law enacting the EU Minimum Tax Directive. On October 22, 2024, Decree No. 13/XVI of the Portuguese Parliament was issued to approve a law to introduce, an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR), as well as a Qualified Domestic Minimum Top-up Tax (QDMTT), which allows Portugal to collect top-up taxes on low-taxed Portuguese entities of both foreign and domestic groups. The law applies for tax years beginning on or after 1 January 2024 for the IIR and QDMTT, and tax years beginning on or after 1 January 2025 for the UTPR. On September 11, 2024, the Portuguese Council of Ministers approved a law to implement the EU Minimum Tax Directive into domestic law. On July 10, 2024, the Portuguese government issued a draft law to transpose the EU Minimum Tax Directive into domestic law. The public consultation is open until 31 July 2024. | – | Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament |
| Qatar | Qatar: GloBE Country Guide | On March 27, 2025, Law No. 22 of 2024 amending certain provisions of Income Tax Law No. (24) of 2018 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule (IIR) and a Domestic Minimum Top- Up Tax (DMTT which is intended to be a Qualified Domestic Minimum Top-Up Tax) from January 1, 2025. | Qatar Enacts a Pillar Two Income Inclusion Rule and Domestic Minimum Tax | |
| Romania | Romania: GloBE Country Guide | On February 7, 2025, Order no. 193 of 2025 was published in the Official Gazette. This provides amendments to the income tax return (form 100) to report amounts due under the IIR/UTPR or DMTT. On December 29, 2023, Law No. 431/2023 to implement the EU Minimum Tax Directive was published in the Official Gazette. On December 19, 2023, the Romanian Parliament approved the ‘Draft Law on ensuring a global minimum level of taxation for MNE Groups and Large National Groups’. On October 4, 2023, the Romanian Ministry of Finance issued a draft law to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. See our English Translation | Explanatory Notes | Romania Issues Order to Amend CIT Return for Global Minimum Tax A Review of Romania’s Draft Pillar Two Law |
| Singapore | Singapore: GloBE Country | On December 30, 2024, Singapore published the Multinational Enterprise (Minimum Tax) Regulations 2024 which provide for the detailed rules for the application of the multinational top-up tax (MTT) and domestic top-up tax (DTT). On November 27, 2024, the Multinational Enterprise (Minimum Tax) Act 2024 was published in Singapore’s Official Gazette. On October 15, 2024, Singapore’s Parliament passed the Multinational Enterprise (Minimum Tax) Bill which includes a multinational top-up tax (MTT) and a domestic top-up tax (DTT). On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours (Transitional Country-by-Country Reporting Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour). On September 9, 2024, Singapore introduced its Multinational Enterprise (Minimum Tax) Bill, 2024 into Parliament. The Bill is based on the previously issued draft law, with a number of amendments. On June 10, 2024, the Singapore Ministry of Finance issued a draft Multinational Enterprise (Minimum Tax) Bill and subsidiary legislation for consultation. The consultation is open until July 5, 2024. | Explanatory Statement | Singapore Issues Final Regulations for the Application of the Global Minimum Tax Singapore Global Minimum Tax Law has been Published in the Official Gazette Singapore Issues Draft Legislation for OECD Safe Harbours |
| Slovakia | Slovakia: GloBE Country Guide | On September 11, 2024, the government of Slovakia approved a draft bill on amendments to the law to reflect various aspects of the OECD Administrative Guidance. This was approved by Parliament on November 28, 2024 and published in the Official Gazette on December 17, 2024. On December 23, 2023, Act No. 507/2023 to implement relevant provisions of the EU Minimum Tax Directive, was published in the Official Gazette. On December 4, 2023, the Slovakian Government approved the ‘Draft Act on the Equalization Tax to ensure a minimum level of taxation for multinational enterprise groups and large national groups’. The draft law was passed by the Legislative Council on December 8, 2023. | Slovakian Parliament Approves the GMT Amendment Law Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision |
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| Slovenia | Slovenia: GloBE Country Guide | On December 22, 2023, the Minimum Tax Act (to implement the EU Minimum Tax Directive), was published in the Official Gazette of the Republic of Slovenia, No. 131/23. | Slovakia, Slovenia, Croatia and Bulgaria Gazette Pillar Two Laws | |
| South Africa | South Africa: GloBE Country Guide | On December 24, 2024, South Africa published the Global Minimum Tax Act in its Official Gazette. This applies an IIR and QDMTT from January 1, 2024. On January 9, 2025, the Global Minimum Tax Administration Act 47 of 2024 was published. On October 30, 2024 the Global Minimum Tax Bill and the Global Minimum Tax Administration Bill were sent to the National Assembly. On February 21, 2024, the National Treasury and the South African Revenue Service issued the Draft Global Minimum Tax Bill, and the Draft Global Minimum Tax Administration Bill for consultation. | Explanatory Notes | South Africa Gazettes its Global Minimum Tax Act South Africa Country Guide Updated for Latest Draft Laws South Africa Issues a Draft Law to Transpose the OECD GloBE Rules & Adopts an ‘Ambulatory’ Approach |
| South Korea | South Korea: GloBE Country Guide | Decree of the Ministry of Economy and Finance No. 1114 of March 21, 2025 amending the Enforcement Regulations to the International Tax Adjustment Act. Presidential Decree 35348 of February 28, 2025 amending the Enforcement Decree to the International Tax Adjustment Act. On December 31, 2024, Law No. 20612, was published to amend the Global Minimum Tax Act for the 2025 Tax Reform provisions. On July 25, 2024, the Ministry of Economy and Finance issued the 2024 Tax Law Amendment Bill. This includes a number of amendments to the South Korean global minimum tax law to reflect aspects of the OECD Administrative Guidance. On March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended for GloBE adjustments. This includes attachments for the GIR (in English and Korean) and the GloBE Tax Return. On February 29, 2024, the Enforcement Decree to the International Tax Adjustment Act was amended to reflect aspects of the GloBE rules. On December 31, 2023, Law 19928 was issued to amend the International Tax Adjustment Act. On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Mediation Act. On December 31, 2022, South Korea passed Law 19191 to amend the International Tax Adjustment Act to provide for the Pillar Two Global Minimum Tax from January 1, 2024. On July 28, 2023, the South Korean government published the Partial Amendment Proposal for the International Tax Adjustment Act, to amend their Pillar Two law to (1) take account of a number of OECD amendments issued in their Administrative Guidance, and (2) delay the implementation of the UTPR until January 1, 2025. On July 22, 2022, South Korea released a draft law to implement Pillar Two. See our English Translations | South Korea’s updated Enforcement Regulation and Enforcement Decree provides for OECD Administrative Guidance Updates South Korea Issues 2025 Amendments to its Global Minimum Tax Law South Korea’s 2024 Tax Law Amendment Bill Includes Pillar 2 Updates A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation A Review of South Korea’s Latest GloBE Amendments South Korea Issues Draft Pillar 2 Amendment Law First Domestic Pillar Two Global Minimum Tax Law Enacted Analysis of South Korea’s Draft Pillar Two Law English Translation of South Korean Pillar Two Law |
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| Spain | Spain: GloBE Country Guide | On April 2, 2025, Spain issued Royal Decree 252/2025 to approve the Regulations for the Global Minimum Tax. The Regulations include a number of aspects of the OECD Administrative Guidance. On December 21, 2024, Spain published law 7/2024 in its Official Gazette to transpose the EU Minimum Tax Directive. This includes an IIR and QDMTT from December 31, 2023 and the UTPR from December 31, 2024. On December 19, 2024, Spain’s Parliament approved the law to transpose the EU Minimum Tax Directive. On December 4, 2024, Spain issued a draft decree which includes Regulations for the application of the Global Minimum Tax Law. This is subject to a public consultation. On December 19, 2023, Spain’s Council of Ministers approved a draft law to implement the EU Minimum Tax Directive. It was subject to a consultation and was then subsequently approved as a second draft by the Council of Ministers on June 4, 2024. On June 14, 2024, the Official Gazette of the Spanish Parliament published the text of the Bill. The first draft law was published on December 20, 2023 | Spain Issues Regulations for the Global Minimum Tax Act Spain Enacts its Global Minimum Tax Law Spain Opens a Consultation on the Global Minimum Tax |
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| Sweden | Sweden: GloBE Country Guide | On March 20, 2025, Sweden issued proposed amendments to its Global Minimum Tax Act for consultation. The amendments are primarily to implement the OECDs June 2024 Administrative Guidance. On October 15, 2024, the Swedish government approved a bill amending the country’s global minimum tax legislation. This includes aspects of the OECD Administrative Guidance, including the December 2023 Safe Harbour amendments. This was approved by Parliament on December 4, 2024. On March 19, 2024, the Swedish Ministry of Finance published proposals, including draft legislation, to amend its GloBE law to include further aspects of the OECD Administrative Guidance. On December 16, 2023, the Swedish Official Gazette published Law No. SFS 2023:875, implementing the EU Minimum Tax Directive. See our English Translation | Explanatory Notes 1 Explanatory Notes 2 | Sweden Issues a Draft Law to Amend its Global Minimum Tax Act for June 2024 OECD Administrative Guidance Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance Review of the Draft Swedish Global Minimum Tax Law |
| Switzerland | Switzerland: GloBE Country Guide | On November 20, 2024, the Swiss Federal Council issued the amended Minimum Tax Ordinance to apply the IIR from January 1, 2025. On September 4, 2024, the Swiss Federal Council announced that the IIR is to apply from January 1, 2025. On December 22, 2023, the Swiss Federal Council issued an Ordinance and announced Switzerland is to apply a QDMTT from December 31, 2023. The IIR and UTPR are to be delayed. On August 17, 2022, the Swiss Federal Council issued a draft decree for the implementation of Pillar Two. On May 24, 2023, Switzerland issued an updated Draft Decree for the Pillar Two Global Minimum Tax. See our English Translation | Explanatory Notes to the Amended Minimum Tax Ordinance Explanation | Swiss Federal Council Issues Amended Minimum Tax Ordinance for the IIR Switzerland Applies IIR From January 1, 2025 Switzerland Issues Second Consultation on the GloBE Rules Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand Analysis of Switzerlands Draft Pillar Two Decree Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand Switzerland Issues Second Consultation on the GloBE Rules |
| Thailand | Thailand: GloBE Country Guide | On December 26, 2024, Thailand published the Emergency Decree on Top-up Tax, B.E. 2567 (2024) in its Official Gazette to implement the GloBE provisions from January 1, 2025. On March 1, 2024, the Thai Revenue Department published an 18-page consultation paper on the implementation of Pillar Two. This includes draft legislation which includes, an IIR, UTPR and a domestic minimum tax. | Thailand Issues Emergency Decree for for IIR, UTPR and Domestic Top-Up Tax Thailand Issues Draft Pillar Two Legislation |
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| The Netherlands | Netherlands: GloBE Country Guide | The Dutch Minimum Tax Executive Decree 2024 was published in the Government Gazette on December 23, 2024. This Executive Decree incorporates various parts of the OECD Administrative Guidance into Dutch law, and provides additional detail where the main Minimum Tax Act stated that further detailed rules would be provided (eg for Blended CFC regimes and substitute loss carry forwards). The Decree enters into force on January 1, 2025 and has retroactive effect to December 31, 2023. On September 17, 2024, a draft law to amend the Minimum Tax Act was published. This includes a number of amendments to implement the OECD Administrative Guidance. On October 3, 2024, a further amendment to the draft law was published. The draft law was approved by Parliament on December 17, 2024. On December 27, 2023, the Dutch Official Gazette published the 2024 Tax Plan which includes the Minimum Tax Act to implement the EU Minimum Tax Directive. On December 19, 2023, the Dutch Senate approved the 2024 Tax Plan which includes the Minimum Tax Act to implement the EU Minimum Tax Directive. On 13 October 2023, the Dutch State-Secretary of Finance issued a Bill to amend the Dutch Draft Minimum Tax Bill. The Netherlands presented the Minimum Tax Bill, 2024 to Parliament on May 31, 2023. See our English Translation | Memorandum of Amendment to to Minimum Tax Act | The Netherlands Issues Executive Regulations to Implement Aspects of the OECD Administrative Guidance The Netherlands Parliament Approves Law to Amend its Global Minimum Tax Law for OECD Administrative Guidance The Netherlands Issues GloBE Amendments for OECD Administrative Guidance The Netherlands Sends GloBE Minimum Tax Act to Parliament Key Takeaways From the Dutch Draft Pillar Two Legislation |
| The United Kingdom | United Kingdom: GloBE Country Guide | On March 31, 2025, the UK issued the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025. This outlines which jurisdictions have implemented a qualified income inclusion rule, a QDMTT and which QDMTTs qualify for the QDMTT Safe Harbour. On November 20, 2024, the UK issued guidance on how to replace a filing member for Pillar 2 purposes On November 20, 2024, the UK issued guidance on how and when to pay Pillar 2 top-up tax. On November 7, 2024, the Finance Bill 2024-2025 was introduced to Parliament. This includes provisions to enact the UTPR (and associated rules such as the Transitional UTPR Safe Harbour and Initial Phase of International Activity Exemption), and other Pillar 2 amendments. On December 19, 2024, the UK issued amendments to the Finance Bill 2024/2025 which includes amendments for the June 2024 OECD Administrative Guidance. This was further amended on January 27, 2025. On March 20, 2025, the Finance Act, 2025 received Royal Assent. In the UK 2024 Budget on October 30, 2024, it was confirmed that: • The UTPR is to apply from 2025 • The transitional CbCR anti-arbitrage rules are to be implemented (effective from the publication of the Written Ministerial Statement on March 14, 2024). Other amendments are also to be made to the MTT and DTT regime for technical changes and to provide for the Fourth Set of OECD Administrative Guidance. On September 12, 2024, the UK issued further draft guidance on the Multinational Top-up Tax and Domestic Top-up Tax. The issued draft guidance now runs to over 300 pages. On July 29, 2024, the UK government issued Draft Legislation for the Hybrid Arbitrage Arrangement Anti-Avoidance Rule On July 18, 2024, the UK issued draft legislation to implement the UTPR. On May 20, 2024, the UK issued a Pillar 2 top-up taxes registration notice, that explains how to register for Pillar 2 top-up taxes in the UK, the information required and how to notify HMRC of any reporting related changes. On February 22, 2024, the UK 2024 Finance Act received royal assent. This domestically implements amendments provided in the OECD Administrative Guidance. On December 21, 2023, the UK issued detailed draft guidance on various aspects of the UK’s multinational top-up tax, including how to calculate the ETR. Finance (No. 2) Act for the ‘Multinational Top-Up Tax‘ enacted on July 11, 2023. On June 15, 2023, the UK issued draft guidance on the application of the multinational top-up tax. | Draft MTT and DTT Guidance (January 2025) Explanatory Notes to the 2024-2025 Finance Bill Draft Guidance – September 2024 Draft Guidance Notes | Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025 UK Issues Draft Legislation for the Hybrid Arbitrage Anti-Avoidance Rule UK Enacts 2024 Finance Act to Implement the OECD Administrative Guidance Review of the UK Draft UTPR Law UK Enacts New Multinational Top-Up Tax From December 31, 2023 UK Issues First Tranche of Draft Guidance on Global Minimum Tax Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill UK Proposes Amendments to Global Minimum Tax Rules |
| Turkey | Turkey: GloBE Country Guide | The Law on the Amendment of Tax Laws and Certain Laws” was published in the Turkish Official Gazette on August 2, 2024. Articles 37 – 50 of the Law include provisions to implement the GloBE rules in domestic law from January 1, 2024. This includes the IIR, UTPR (from 2025) and a domestic minimum top-up tax. | – | Turkey Enacts its Pillar Two Law Turkey Gazettes Pillar 2 IASB Amendments |
| United Arab Emirates | The UAE: GloBE Country Guide | On April 16, 2025, the Ministry of Finance issued Ministerial Decision No. (88) of 2025 to provide for the application of the OECD Administrative Guidance from January 1, 2025. On March 4, 2025, the UAE Ministry of Finance issued updated FAQs on the DMTT, including the expectation that it will be listed as a QDMTT in the OECD peer review process and the general operation of the DMTT in the UAE. On February 8, 2025, the Ministry of Finance issued Cabinet Resolution 142 of 2024 for the detailed provisions for the application of the DMTT. On December 9, 2024, the UAE Ministry of Finance confirmed it will implement a 15% DMTT (that will align with the GloBE rules) from January 1, 2025. The legislation has not yet been issued On 24 November 2023, the UAE released Federal Decree Law No. 60 of 2023, which amends some provisions of the Federal Decree Law No 47 of 2022 (“CIT Law”) to provide for a Pillar 2 top-up tax. | – | UAE Issues Ministerial Decision to Implement the OECD Administrative Guidance UAE Issues a Cabinet Decision on the Pillar Two Domestic Minimum Tax |
| Vietnam | Vietnam: GloBE Country Guide | On November 12, 2024, the Vietnamese Ministry of Finance released a draft Decree on the implementation of Resolution No. 107/2023/QH15 on the Global Minimum Tax. The draft decree provides for the detailed application of the GloBE rules in Vietnam. On December 8, 2023, Resolution No: 107/2023/QH15 was issued to enact the Pillar Two GloBE rules. It was published in the Vietnamese Official Gazette on December 21, 2023 | Vietnam Issues a Draft Decree for Detailed GloBE Provisions Vietnamese Parliament Approves QDMTT From 2024 Vietnam Issues Draft Pillar 2 Resolution |
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